Retrospective reanalysis of clinical study data (K121710); Published clinical literature
The sponsor reanalyzed existing clinical study data from 36 geographically diverse clinical sites to evaluate the performance of the Xpert CT/NG assay in pregnant women. The reanalysis focused on 106 pregnant subjects identified within the original clinical cohort. Published literature was also provided to support the safety and effectiveness of the device in this population.
Retrospective reanalysis; Clinical study data; Pregnant women; Literature review
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Reanalysis of K121710 Clinical Study Data; Retrospective reanalysis of a multi-site clinical study
106 pregnant women (subset of 3781 total female subjects); Sample Size: 106; Number of Sites: 36
Patient Infected Status (PIS)
Sensitivity and specificity
Indications for Use
The Xpert® CT/NG Assay, performed on the GeneXpert® Instrument Systems, is a qualitative in vitro real-time PCR test for the automated detection and differentiation of genomic DNA from Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) to aid in the diagnosis of chlamydial and gonorrheal urogenital disease. The assay may be used to test the following specimens from asymptomatic and symptomatic individuals: female and male urine, endocervical swab, and patient-collected vaginal swab (collected in a clinical setting).
Device Story
Xpert CT/NG Assay is an automated, multiplex real-time PCR test for qualitative detection/differentiation of Chlamydia trachomatis and Neisseria gonorrhoeae DNA. Input samples include urine, endocervical swabs, and patient-collected vaginal swabs. The device uses single-use disposable cartridges containing PCR reagents; the GeneXpert Instrument System automates sample purification, nucleic acid amplification, and target sequence detection. The system includes an instrument, PC, and preloaded software. Modules feature a syringe drive for fluidics, ultrasonic horn for cell/spore lysis, and I-CORE thermocycler for PCR. Output is a qualitative result provided to clinicians to aid in diagnosing urogenital infections. The device is used in clinical settings; it benefits patients by providing rapid, automated diagnostic results to guide treatment decisions.
Clinical Evidence
The device relies on clinical data from the predicate (K121710). A reanalysis of clinical study data from K121710 was performed specifically for specimens collected from pregnant women to support the removal of a previous performance limitation.
Technological Characteristics
Multiplex real-time PCR; 5' exonuclease detection. Includes internal controls: Sample Processing Control (SPC), Sample Adequacy Control (SAC), and Probe Check Control (PCC). Form factor: single-use disposable cartridges. Instrument: GeneXpert System (Dx, Infinity-48, Infinity-80). Connectivity: wired data transmission to PC. Software: preloaded system software.
Indications for Use
Indicated for symptomatic and asymptomatic individuals, including pregnant women, for the qualitative detection and differentiation of Chlamydia trachomatis and Neisseria gonorrhoeae DNA in female/male urine, endocervical swabs, and patient-collected vaginal swabs to aid in the diagnosis of urogenital disease.
Regulatory Classification
Identification
Neisseria spp. direct serological test reagents are devices that consist of antigens and antisera used in serological tests to identify Neisseria spp. from cultured isolates. Additionally, some of these reagents consist of Neisseria spp. antisera conjugated with a fluorescent dye (immunofluorescent reagents) which may be used to detect the presence of Neisseria spp. directly from clinical specimens. The identification aids in the diagnosis of disease caused by bacteria belonging to the genus Neisseria, such as epidemic cerebrospinal meningitis, meningococcal disease, and gonorrhea, and also provides epidemiological information on diseases caused by these microorganisms. The device does not include products for the detection of gonorrhea in humans by indirect methods, such as detection of antibodies or of oxidase produced by gonococcal organisms.
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
K173840
B. Purpose for Submission:
To change a limitation statement pertaining to pregnant women in the Cepheid Xpert CT/NG Assay package insert
C. Measurand:
Genomic DNA of *Chlamydia trachomatis* (CT) and/or *Neisseria gonorrhoeae* (NG)
D. Type of Test:
Real Time Polymerase Chain Reaction
E. Applicant:
Cepheid
F. Proprietary and Established Names:
Xpert CT/NG
G. Regulatory Information:
1. Regulation section:
21 CRF 866.3990, *Neisseria* spp. direct serological test reagents
2. Classification:
Class II
3. Product code:
LSL: DNA-Reagents, Neisseria
MKZ: DNA Probe, Nucleic Acid Amplification, Chlamydia
OOI: Real Time Nucleic Acid Amplification System
4. Panel:
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Microbiology (83)
## H. Intended Use:
1. Intended use(s):
Xpert CT/NG Assay
The Xpert CT/NG Assay, performed on the GeneXpert Instrument Systems, is a qualitative *in vitro* real-time PCR test for the automated detection and differentiation of genomic DNA from *Chlamydia trachomatis* (CT) and/or *Neisseria gonorrhoeae* (NG) to aid in the diagnosis of chlamydial and gonorrheal urogenital disease. The assay may be used to test the following specimens from asymptomatic and symptomatic individuals: female and male urine, endocervical swab, and patient-collected vaginal swab (collected in a clinical setting).
Ancillary Collection Kits
Xpert Vaginal/Endocervical Specimen Collection Kit
The Cepheid Xpert Vaginal/Endocervical Specimen Collection Kit is designed to collect, preserve and transport *Chlamydia trachomatis*, *Neisseria gonorrhoeae*, and *Trichomonas vaginalis* DNA in endocervical swab specimens (collected by a clinician) and patient-collected vaginal swab specimens (collected in a clinical setting) from symptomatic and asymptomatic women prior to analysis with the Xpert CT/NG Assay and the Xpert TV Assay.
Xpert Urine Specimen Collection Kit
The Cepheid Xpert Urine Specimen Collection Kit is designed to preserve and transport *Chlamydia trachomatis*, *Neisseria gonorrhoeae*, and *Trichomonas vaginalis* DNA in first-catch male and female urine specimens from symptomatic and asymptomatic individuals prior to analysis with the Xpert CT/NG Assay and the Xpert TV Assay.
2. Indication(s) for use:
Same as Intended Use.
3. Special conditions for use statement(s):
For Prescription Use
4. Special instrument requirements:
To be used only with the GeneXpert Instrument Systems
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I. Device Description:
The Xpert CT/NG Assay is an automated *in vitro* diagnostic test for qualitative detection and differentiation of DNA from *Chlamydia trachomatis* (CT) and/or *Neisseria gonorrhoeae* (NG).
The Xpert CT/NG assay is performed on the Cepheid GeneXpert Instrument Systems. The GeneXpert Instrument System consists of an instrument, personal computer, and preloaded software for running tests and viewing the results. The system requires single-use, disposable cartridges that hold the PCR reagents and host the PCR process. It automates and integrates sample purification, nucleic acid amplification, and detection of the target sequences in the urogenital samples using real-time PCR for gene specific sequence amplification.
The Xpert CT/NG Assay includes reagents for the 5’ exonuclease real-time PCR detection and differentiation of CT and NG. Reagents for the detection of a Sample Processing Control (SPC), a Sample Adequacy Control (SAC), and a Probe Check Control (PCC) are also included in the cartridge. The SPC is present to control for adequate processing of the target bacteria and to monitor the presence of inhibitors in the PCR reaction. The SAC reagents detect the presence of a single copy human gene and monitor whether the specimen contains human DNA. The PCC verifies reagent rehydration, PCR tube filling in the cartridge, probe integrity, and dye stability. The primers and probes in the Xpert CT/NG Assay detect chromosomal sequences in the bacteria.
The Xpert CT/NG Assay is desined for use with urogenital specimens collected using the ancillary specimen collection kits (described in section H above). The specimen collected from asymptomatic or symptomatic individual is briefly mixed and transferred to the sample chamber of the Xpert CT/NG cartridge using the supplied transfer pipette. The cartridge is loaded onto the GeneXpert Instrument System platform, which performs hands-off, automated sample processing and real-time PCR for detection of DNA. Test results are obtained in approximately 90 minutes and are displayed in tabular and graphic formats.
J. Substantial Equivalence Information:
1. Predicate device name(s):
Xpert CT/NG
2. Predicate 510(k) number(s):
K121710
3. Comparison with predicate:
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Table 1: Similarities between Cepheid Xpert CT/NG and Predicate Device
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate Device |
| | Cepheid Xpert CT/NG(K173840) | Cepheid Xpert CT/NG(K121710) |
| Regulation | 866.3390 | 866.3390 |
| Device Class | II | II |
| Technology/Detection | Multiplex real-time polymerase chain reaction | Same |
| Intended Use | The Xpert CT/NG Assay, performed on the GeneXpert Instrument Systems, is a qualitative in vitro real-time PCR test for the automated detection and differentiation of genomic DNA from Chlamydia trachomatis (CT) and/or Neisseria gonorrhoeae (NG) to aid in the diagnosis of chlamydial and gonorrheal urogenital disease. The assay may be used to test the following specimens from asymptomatic and symptomatic individuals: female and male urine, endocervical swab, and patient-collected vaginal swab (collected in a clinical setting).Ancillary Collection Kits:Xpert Vaginal/Endocervical Specimen Collection KitThe Cepheid Xpert Vaginal/Endocervical Specimen Collection Kit is designed to collect, preserve, and transport Chlamydia trachomatis, Neisseria gonorrhoeae, and Trichomonas vaginalis DNA in endocervical swab specimens (collected by a clinician) and patient-collected vaginal swab specimens (collected in a clinical | Same |
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| Similarities |
| --- |
| Item | Device | Predicate Device |
| Item | Cepheid Xpert CT/NG (K173840) | Cepheid Xpert CT/NG (K121710) |
| | setting) from symptomatic and asymptomatic women prior to analysis with the Xpert CT/NG Assay and the Xpert TV Assay.
Xpert Urine Specimen Collection Kit
The Cepheid Xpert Urine Specimen Collection Kit is designed to preserve and transport *Chlamydia trachomatis*, *Neisseria gonorrhoeae*, and *Trichomonas vaginalis* DNA in first-catch male and female urine specimens from symptomatic and asymptomatic individuals prior to analysis with the Xpert CT/NG Assay and the Xpert TV Assay. | |
| Assay Targets | DNA from *Chlamydia trachomatis* (CT) and/or *Neisseria gonorrhoeae* (NG) | Same |
| Specimen Type | Urine (male and female), endocervical swab, and patient-collected vaginal swab (collected in a clinical setting) | Same |
| CT Analyte Targets | CT genomic DNA | Same |
| NG Analyte Targets | NG genomic DNA | Same |
| Collection Kit | Urine collection kit
Swab collection kit | Same |
| Nucleic Acid Extraction | Yes | Yes |
| Assay Controls | Internal sample processing control (SPC), sample adequacy control (SAC), and probe check control (PCC) | Same |
| Assay Results | Qualitative | Same |
| Instrument System | Cepheid GeneXpert | Same |
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| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate Device |
| | Cepheid Xpert CT/NG (K173840) | Cepheid Xpert CT/NG (K121710) |
| | Instrument Systems | |
| Time to test results | Approximately 90 minutes (1.5 hours) to results. | Same |
Table 2: Differences Between Cepheid Xpert CT/NG and Predicate Device
| Differences | | |
| --- | --- | --- |
| | Device | Predicate Device |
| Item | Cepheid Xpert CT/NG (K173840) | Cepheid Xpert CT/NG (K121710) |
| Limitation | Xpert CT/NG Assay performance has not been evaluated in patients with a history of hysterectomy. | Xpert CT/NG Assay performance has not been evaluated in pregnant women, or in patients with a history of hysterectomy. |
# K. Standard/Guidance Document Referenced (if applicable):
1. BS EN ISO 23640, In vitro diagnostic medical devices. Evaluation of Stability Testing of in vitro Diagnostic Reagents, June 2015.
2. ASTM D4169-2005 and ASTM D4169-2009, Standard Practice for Performance Testing of Shipping Containers and Systems.
3. CLSI EP5-A2, Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline -Second Edition.
4. CLSI MM3-A2, Molecular Diagnostic Methods for Infectious Disease; Approved Guideline -Second Edition.
5. Nucleic Acid Based In Vitro Diagnostic Devices for Detection of Microbial Pathogens - Draft Guidance for Industry and FDA Staff, December 8, 2005.
6. Guidance for Industry and FDA Staff, Format for Traditional and Abbreviated 510(k), August 12, 2005.
7. Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Instrumentation for Clinical Multiplex Test Systems, March 10, 2005.
8. Guidance for Industry- Cybersecurity for Network Medical devices containing Off-the-shelf (OTS) Software, issued January 14, 2005.
9. Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices - Guidance for Industry and FDA Staff, May 11, 2005.
10. Guidance for Off-the-Shelf Software Use in Medical Devices; Final, September 9, 1999.
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L. Test Principle:
This assay amplifies Chlamydia trachomatis and Neisseria gonorrhoeae unique chromosomal gene sequences using real time polymerase chain reaction technology. The amplified DNA is detected by fluorogenic target-specific probe hybridization followed by 5'-nuclease cleavage of the probe to release the fluorophore. The resulting fluorescent signal is measured using the GeneXpert instrument system.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Reproducibility and within laboratory precision studies were previously reviewed and described in K121710.
b. Linearity/assay reportable range:
Not Applicable; this is a qualitative assay.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Specimen stability and controls were previously reviewed and described in K121710.
d. Detection limit:
Limit of detection study was previously reviewed and described in K121710.
e. Analytical reactivity:
Inclusivity was previously reviewed and described in K121710.
f. Analytical specificity:
Cross-reactivity with relevant microorganisms and interference by potentially interfering substances were previously reviewed and described in K121710.
g. Carryover/Cross-contamination:
Carryover/Cross-contamination study was previously reviewed and described in K121710.
h. Assay cut-off:
Assay cut-off was previously reviewed and described in K121710.
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2. Comparison studies:
a. Method comparison with predicate device:
Not applicable.
b. Matrix comparison:
Not applicable.
3. Clinical studies:
The clinical data from K121710 was reanalyzed to evaluate the performance of the Xpert CT/NG for urine specimens, endocervical swabs, and patient-collected vaginal swabs (in the clinical setting) collected from pregnant women. Please refer to the decision summary of K121710 for the details of the clinical study. The specimens included in K121710 clinical study were collected at 36 geographically diverse sites (including four sites located in the United Kingdom) from consenting asymptomatic and symptomatic, sexually active males and females seen at locations including, but not limited to: OB/GYN, sexually transmitted disease (STD), teen, public health, and family planning clinics. The samples were tested at 15 sites. The clinical study included 3781 eligible female subjects; the current submission included reanalysis of data for 106 women pregnant at the time of specimen collection amongst the 3781 eligible women. Result obtained by the Xpert CT/NG for each claimed specimen type (endocervical swab, patient-collected vaginal swab, and female urine specimen) was evaluated against the Patient Infected Status (PIS). The Xpert CT/NG showed a point estimate of 100% for both sensitivity and specificity with endocervical, patient-collected vaginal swab, and urine from pregnant females. Additionally, published clinical literature was provided that supported the use of the Xpert CT/NG in pregnant women.
4. Clinical cut-off:
Not applicable
5. Expected values/Reference range:
Please refer to the decision summary of K121710.
N. Instrument Name:
GeneXpert Instrument Systems
- GeneXpert Dx System
- GeneXpert Infinity-48 System
- GeneXpert Infinity-80 System
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O. System Descriptions:
1. Modes of Operation:
Does the applicant’s device contain the ability to transmit data to a computer, webserver, or mobile device?
Yes ☐ X ☐ or No ☐
Does the applicant’s device transmit data to a computer, webserver, or mobile device using wireless transmission?
Yes ☐ or No ☐ X ☐
2. Software:
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☐ X ☐ or No ☐
3. Specimen Identification:
Specimen identification is performed with a barcode scanner or by manually entering the information into GeneXpert system software.
4. Specimen Sampling and Handling:
Specimen handling is performed in either an Automation Mode or in a Manual Mode. In the Automation Mode, test cartridges are placed on a conveyor belt, picked up by a gantry, and introduced into an available module for processing.
5. Calibration:
Calibration is performed by Cepheid prior to installation. The user does not calibrate or perform any serviceable functions on the instruments. A calibration check is recommended on the annual basis. In the GeneXpert Operator’s Manual, the user is instructed to contact Cepheid Technical Support for information about calibration.
6. Quality Control:
The integrity of the system is verified and controlled by specific hardware/software checks during the cartridge load process, and during the test itself. The Xpert CT/NG includes a sample adequacy control to verify that human DNA is present in the sample, a sample processing control to verify adequate processing of sample, and a probe check control to ensure adequate regaent rehydration, probe integrity, and dye stability.
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P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
N/A
Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
10
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.